Archive for category: Consulting / Assessment

Naturally Occurring Asbestos in Construction is Getting a Closer Look by Cal/OSHA

Building owners and property managers familiar with asbestos may not automatically think of the asbestos that occurs naturally in soil and rock. Most people associate asbestos exposure with hazardous building materials found during renovation, tenant improvements, and related demolition.

Asbestos is a fibrous silicate mineral with unique properties including flexibility, high tensile strength, and chemical and heat resistance. In California, chrysotile is the most abundant form of asbestos and commonly found in serpentine rock, which happens to be the official state rock.  Naturally occurring asbestos, or NOA, can be found in 42 of the 58 counties that make up California. When rock and soil containing NOA is disturbed, asbestos fibers are released into the air where they can potentially be inhaled. Construction sites where NOA is present can pose serious health risks to construction workers. Cal/OSHA is now closely examining and revising safety order standards to protect employees from exposure to NOA during construction.

Cal/OSHA to Hold Advisory Meetings to Address Naturally Occurring Asbestos in Construction

In August 2019, Cal/OSHA announced the formation of an advisory committee to “consider development of a rulemaking proposal addressing work with naturally occurring asbestos in the construction industry.” Cal/OSHA is expected to discuss the “classification of work, methods of compliance, hygiene facilities and practices, training, and competent persons” at the first advisory meeting.

Discussions are moving forward after the Cal/OSHA Occupational Safety and Health Standards Board granted approval to Petition 568, which requests an amendment to Title 8, Section 1529 of the Construction Safety Orders, which relates to asbestos regulations. Filed by the Naturally Occurring Asbestos Regulations Task Group, the petition requests a number of additions to the existing standards.

Whether these advisory meetings will lead to the development of an official rulemaking proposal remains to be seen, but recent cases from construction sites in Clark County, Nevada, show that what we know about NOA is just the tip of the iceberg.

What You Need to Know About Existing Standards for Naturally Occurring Asbestos in Construction

Employee exposure to NOA, compared to ACMs (Asbestos-Containing Materials), can be difficult to assess and mitigate because existing standards are so ambiguous and there is little guidance for a step-by-step identification process. However, the California Air Resources Board has adopted two Airborne Toxic Control Measures for NOA exposure at construction sites: the ATCM for Surfacing Applications and the ATCM for Construction, Grading, Quarrying and Surface Mining (17 CCR 93105). The ARB Test Method 435 is used for sampling and analysis of NOA.

The U.S. EPA is technically responsible for enforcement of federal asbestos regulation in demolition and construction but can delegate authority to local and state jurisdictions. The Air Resources Board has the delegated authority to enforce all federal regulations for asbestos, including NOA.

The most explicit reference to NOA in construction is included in Cal/OSHA’s existing asbestos standard, Title 8, Section 1529 part (a)(G), which discusses the scope of the regulation: “Excavation which may involve exposure to asbestos as a natural constituent which is not related to asbestos mining and milling activities.”

Property managers or property owners may not even know NOA is present at a site until soil sampling is conducted or an environmental site assessment is completed, but there is no soil sampling or environmental testing requirement in the current Cal/OSHA Title 8 standards. Additionally, several types of NOA may be found at construction sites, and standards for exposure to certain types of asbestos fiber may be more stringent than others, depending on what the advisory committee decides.

Omega Can Help You Identify Naturally Occurring Asbestos on Your Construction Site

By conducting Phase I and II Environmental Site Assessments, Omega’s team of experts can help you determine if NOA is present at any property where earthwork (drilling, boring, etc.) may disturb asbestos-containing soil and/or rock. During a Phase I Site Assessment, Omega will conduct a thorough site visit to determine past and present conditions of the property. This includes reviewing state and agency records, local records, and interviews. In cases where the presence of NOA is well-known, Omega can conduct a Phase II Environmental Site Assessment, which includes surface soil sampling, to confirm and further characterize the presence of asbestos on site. Omega’s Certified Asbestos Consultants can assist in developing an exposure control plan for employees who may come into contact with NOA on a job site.

Contact us to learn more about identifying NOA on a job site and how to protect workers from exposure.

Contact Us to Learn More About Environmental Assessment

Revision to Cal/OSHA Lead Exposure Standard Plan Will Result in Stricter Rules for Employers

California employers in the construction and general industries can expect another revision to lead exposure standards to be finalized by September 2020. In June 2019, Governor Gavin Newsom approved Senate Bill 83, which requires Cal/OSHA to adopt a revised lead exposure standard. The proposed goal of the bill is to protect the health and safety of construction workers by lowering the permissible exposure limit (PEL) for airborne lead from 50 to 10 micrograms per cubic meter (μg/m³) of air calculated as an 8-hour time-weighted average (TWA). Additionally, the proposed changes would lower the lead action level (AL) from 30 to 2 μg/m³ over an 8-hour TWA. The new standard will apply to lead workers in both general industry and construction-related businesses.

Cal/OSHA has submitted an economic impact analysis of the proposed rule to the California Department of Finance for review. After its review, Cal/OSHA will submit a rulemaking package to the OSHA standards board. The board will then begin formal rulemaking, including public hearings on the proposed rule.

Health and Safety Officials Have Recommended Changes to Lead Exposure Standards for Years

Reducing the PEL to one-fifth of the current standard may seem extreme, but health and safety officials have recommended even less than that. In September 2013, officials from the California Department of Health’s Occupational Lead Poisoning Prevention Program stated in correspondence that it recommended a 10 microgram maximum PEL. In its recommendation to the department, program officials stated that “having chronic blood lead levels (BLLs) in the range of 5 to 10 micrograms per deciliter (µg/dL) poses a health risk to working adults.” Program officials concluded that “in order to prevent chronic BLLs at or above 5 to 10 µg/dL, air lead levels in the workplace must not exceed an 8-hour time-weighted average concentration of 0.5 – 2.1 micrograms lead per cubic meter of air.” It remains to be seen whether Cal/OSHA will move to adopt an even stricter standard than what was previously proposed, but employers should prepare to make changes nonetheless.

Proposed Changes to the Cal/OSHA Lead Standard and Effects on Employers

In addition to lowering the lead action level from 30 to 2 μg/m³ per 8-hour TWA and the permissible exposure level from 50 to 10 μg/m³ per 8-hour TWA, the proposed changes include several other rules that employers should be aware of:

• Employers must provide shower facilities and ensure that individuals exposed above the PEL use the shower at the end of their shift;
• If initial exposure assessment indicates exposure above the action level of 2 μg/m³, the employer must provide blood lead testing and monitor exposed individuals at least annually;
• Employers must provide training on the lead standard, hazards of working with lead, proper hygiene practices, and proper use of PPE to all employees who may be exposed to lead at or above the action level, who conduct trigger tasks, or who may be subject to skin or eye irritation due to lead.

Site Surveys and Lead Assessments for Regulatory Compliance

Omega’s team has decades of experience conducting lead assessments and site surveys to assist our clients with mitigating lead exposure during demolition, construction, renovation, and in manufacturing operations. Our work is trusted by contractors, architects, and engineers on a wide variety of public and private projects, including airports, railways, educational facilities, and historic properties. Contact us to learn about our lead assessment services and how we can help you manage upcoming changes to lead-related regulations.

Contact Us to Learn More About Lead Assessments 

Securing the Safety of One of Tustin’s Historic Sites

Nestled in Tustin, Calif. are two of the largest freestanding wooden structures in the world: a pair of blimp hangars from the 1940s. Once used to house military aircraft, these behemoth buildings now serve as rentable filming locations for movies, tv shows, and have even been featured in Tesla commercials. Additionally, the city uses the hangars to host community and company events, including for H&M and Disney.

As strikingly familiar structures etched into Tustin’s landscape, the hangars are about three football fields in length and 17 stories high – so large you can see them from space. Built almost entirely out of wood near the end of WWII, the hangars housed blimps and other military aircraft used to patrol the West Coast in search of enemy submarines and torpedoes.

The Department of the Navy owns the hangars; however, the city of Tustin will soon manage the structures and is in the process of planning a wide variety of uses for the south hangar.

However, before any future development could start, the city first had to ensure the environmental compliance of this historic site.

Environmental Assessment to Ensure Compliance

In the beginning stages of redevelopment, Omega’s team was brought in to perform a 5-day pre-renovation assessment to evaluate the hangar’s building materials. Partnering with preservation architects from Page & Turnbull, Omega assisted the city of Tustin in the assessment of this historic site to determine if any environmental issues existed and to develop a strategy to mitigate risk and ensure compliance with regulatory guidelines set by the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA).

As experts in environmental management, the Omega team has been protecting the public and ensuring the safety of historic buildings for over 20 years. From microbiological evaluations to lead and asbestos consulting, Omega provides a full range of assessment and remediation services for the reliable and cost-effective management of environmental hazards in preparation for demolition, historic restoration and construction.

A Safe and Exciting Future for Tustin’s Hangars

With the city of Tustin considering everything from an urban center complete with shopping and housing, to a potential entertainment park, the safety of this historic hangar was top of mind. And, with the help of Omega’s team, the site of the southern hangar is ready for the next phase of development.

The site of the hangars, which has been featured in films and TV shows such as The X Files, Star Trek, and Austin Powers, is a core part of the city’s culture. Currently, Tustin officials continue to explore and solidify the plans for the hangar’s redevelopment.

As Omega assists Tustin in the next chapter of the hangars’ history, the city can be confident that these historic buildings have been carefully evaluated for environmental compliance, and that – whatever the future of the structures may be – the public can safely experience a piece of their town’s history.

Interested in learning more about Omega’s services? Reach out today.

Contact Us to Learn More About Environmental Assessment

The Emerging Coronavirus: How Omega Can Help

By Richard L Wade PhD, MPH

Principal Scientist, Omega

The emergence of a viral pneumonia, also called COVID-19, caused by a novel coronavirus in December in Wuhan, China has raised fears around the world as the virus spreads from this highly populated city of over 11 million people to the rest of China and into parts of Europe and North America.

This is a very dynamic disease outbreak and experts’ opinions are mixed regarding its potential to become a major worldwide epidemic. Limited understanding of the virus, including its pathogenicity, ability to change its genetic composition as it migrates from one species to another, incubation period, infectivity and ease of transmission has created uncertainty as to the degree of risk,  even as fears are blamed for driving down the stock market and interrupting supply chains.

The Origins of the Outbreak

This coronavirus appears to have crossed the wild animal barrier at the seafood market in Wuhan, China. This market sold both fish and live wild animals. Coronaviruses are a common type of virus that caused both the MERS and SARS outbreaks. In both of these cases, the virus is believed to have originated in bats and crossed over to civet cats, camels, and other mammals. The virus was then transmitted to humans when they were exposed to live animals infected with the virus.

When the virus first appeared in mid-December, it was thought that only direct contact with these live virus-infected animals would cause respiratory pneumonia in humans. In January however, the incidence of this new type of pneumonia had grown to 400 cases and there was evidence of human to human transmission. Compilations of epidemiological forecasts show that one infected person can transmit the virus to between 1.4 and 2.5 other individuals. By Jan. 31, the number of human cases had grown to 9,700, with over 213 fatalities.  On Jan. 30 the World Health Organization declared the virus to be the cause of a Global Health Emergency.

Risk of Secondary Transmission Seen

These estimates suggest a relatively low person-to-person transmission rate, but may not accurately represent the total number of cases currently in China or those within the 2-14 day incubation period. Other investigators suggest that China currently has up to 100,000 cases of pneumonia caused by this new virus as cases surface around the world caused by the migration of infected people. The U.S., Germany and France have reported secondary person-to-person transmission. In these countries, the secondary transmission was through a person traveling from China who infected one local resident with no exposure to China except for the index case. The infected individuals are in isolation and follow-up with people they may have been in contact with is ongoing.

China has adopted aggressive isolation practices and is limiting transportation programs in attempts to isolate and contain the virus. Other countries have implemented screening efforts to detect and isolate infected individuals. However, research reports from China suggest that screening efforts based solely on body temperature measurements may be inadequate if individuals are transmitting the virus before they have elevated temperatures.

While the virus is a serious threat to human health, it is worth remembering that in the U.S., 15 million people have been infected with influenza this season, with 140,000 hospitalizations and 8,200 deaths, according to the U.S. Centers for Disease Control.

Omega Team Can Help Guide Efforts

At Omega Environmental, our team members have provided guidance to companies, health care facilities, the military and the media on best practice during previous outbreaks including SARS 2003 and Ebola 2015.

Our services can include a wide range of guidance, assessment, remediation and decontamination for environmental and microbial hazards. Our consultants can help your company or institution take the right steps with information, education, assessments and guidelines, including:

• Keeping clients up to date with current science-based findings related to worldwide and regional epidemics
• Developing general protocols for cleanup of environments that may be potentially impacted by COVID-19. These efforts can be conducted as a preemptive procedure or after a coronavirus case has been identified.
• Sanitization and disinfection services for suspected or confirmed COVID-19 exposure
• Designing a site-specific scope of work by Omega’s in-house expert, Dr. Richard Wade, PhD, MPH
• Providing project management and oversight of cleanup, including conducting post-remediation testing using accepted methodology for viral detection and decontamination
• On site monitoring and evaluations including checks of HVAC systems, quantitative sanitation evaluations, general air quality, and site-specific and business-specific risk evaluations

To learn more about Omega Environmental Services, give us a call or click on the link below. Read Omega’s most recent COVID-19 Update newsletter here.

References:

David Fisman MD, MPH Professor of Epidemiology School of Public Health University of Toronto (Novel Corona Virus Transmission Dynamics ProMed/AH/EDR mail post. January 27, 2020.

Wuhan 2019-nCoV. Preprint.  Last accessed January 25, 2019. 2020.

Imai N, Cori A, Dorigatti I, Baguelin M, Donnelly C, Riley S, et
al. Report 3: Transmissibility of 2019-nCoV. Last accessed January 25, 2020.; 2020.

Majumdar M, Mandl K. Early transmissibility assessment of a novel
coronavirus in Wuhan, China. Preprint.  Last accessed January 25, 2020. 2020.

Contact Us to Learn More About Environmental Assessment and Consulting

Join Omega’s Environmental Experts at Military Engineers Symposium

With what is described as “historic” levels of contracting, planning and construction of government projects as backdrop, as well as an increased focus on environmental stewardship and sustainability, the Orange County Post of the Society of American Military Engineers (SAME) will host the organization’s 2019 Federal Business Opportunities Symposium Nov. 14 in Costa Mesa, Calif.

The event is expected to draw more than 250 attendees with a stake in the many infrastructure projects underway across Southern California and will highlight measures being taken to promote infrastructural resiliency and sustainability in the face of challenges like climate change and environmental safety.

SAME’s Resiliency Committee is committed to the development of policies, training, partnerships and technology that will drive infrastructure improvements and development that is environmentally sound and capable of adapting to climate change.

Among the immediate environmental hazards facing the Department of Defense is the contamination of groundwater beneath military bases in California and around the country by per- and polyfluoroalkyl substances (PFAS) – highly toxic components of the firefighting foam used for decades at airports and military bases. Exposure to PFAS, which have been found in wells and public water systems near the bases, is linked to numerous human health risks including cancer, immune system damage, infertility, and more.

Safe and Cost-Effective Assessment and Remediation

At Omega Environmental, we have a long history of working with government and military contractors and engineers to identify and remediate environmental hazards for construction, demolition and renovation projects, including assessment for hazardous materials in soil, groundwater, indoor air and building materials.

Assessment for environmental issues is an important component of infrastructure planning, for both new construction and demolition and rehabilitation.  We provide a full range of building materials assessments for hazards like asbestos, PCBs, lead, and other chemical contaminants to ensure that issues are resolved safely and cost-effectively, keeping projects on track, compliant and on-budget.

To learn more about the work we do to help government and private contractors and engineers plan for and resolve environmental issues, join our members at the symposium, give us a call or click on the link below.

Contact Us to Learn More About Environmental Assessment